On November 20, 2025, the U.S. Federal Energy Regulatory Commission (FERC or the Commission) held its first monthly open meeting since the confirmation and swearing-in of Chairman Laura Swett and Commissioner David LaCerte.[1] It marks the first time FERC has had a full five-member commission since the departures of Commissioner Mark Christie and Chairman Willie Phillips earlier this year. FERC’s first meeting under new leadership coincided with an agenda that underscored urgency and a new strategic direction. The summary below outlines the Commission’s discussion and key actions.
https://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Terence T. Healeyhttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngTerence T. Healey2025-12-02 18:43:012025-12-02 18:43:45FERC’s First Meeting Under New Leadership: Key Takeaways and Signals for 2026
On October 23, 2025, Secretary of Energy Chris Wright directed the Federal Energy Regulatory Commission (FERC) to consider an Advance Notice of Proposed Rulemaking (ANOPR) to initiate rulemaking procedures to “ensure the timely and orderly interconnection of large loads to the transmission systems.” Under the ANOPR, “large loads” are defined as those with a capacity of 20 MW or more, aligning with the definition of “large generation sources” in FERC’s Order No. 2003.
https://energyinfrastructurepulse.sidley.com/wp-content/uploads/sites/7/2025/11/AdobeStock_9699481.jpg451600Sidley Multisitehttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngSidley Multisite2025-11-17 15:03:132025-11-17 15:03:13Bringing Data Centers to the Grid: FERC’s Emerging Large Load Framework
The International Maritime Organization (IMO), the United Nations agency tasked with regulating global shipping, has proposed an international carbon pricing scheme on shipping. The maritime shipping sector has increasingly faced global scrutiny as the contributor of 3% of global greenhouse gas emissions, and IMO’s proposed mechanism would serve as the first global emissions pricing mechanism affecting the shipping sector.
https://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Sidley Multisitehttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngSidley Multisite2025-10-30 15:01:422025-10-30 15:01:42The Trump Administration’s Pushback Against a Global Shipping Carbon Levy
A bipartisan group of governors of PJM Interconnection (PJM) member states has intensified calls for reforming PJM after what they have described as a “crisis of confidence,” citing high electricity prices, interconnection delays, and lack of transparency and state participation in the RTO’s decision-making processes.
https://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Sidley Multisitehttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngSidley Multisite2025-10-09 17:49:562025-10-09 17:49:56Governors of PJM States Intensify Pressure on PJM for Reform
On September 29, 2025, the Council on Environmental Quality (CEQ) issued long-awaited guidance to formalize agencies’ individual efforts to implement the National Environmental Policy Act (NEPA). After rescinding the CEQ regulations that shaped NEPA for 40+ years and bearing witness to various agencies’ independent efforts to issue their own NEPA rules, CEQ issued new guidance to more systematically guide the agencies’ efforts. As CEQ notes, “NEPA implementation reform now has been called for, authorized, and directed by all three branches of government at the highest possible level: Congress, the President, and the Supreme Court.” The guidance reflects direction from each.
https://energyinfrastructurepulse.sidley.com/wp-content/uploads/sites/7/2025/11/MN-21065-Images-for-Environmental-Blog-14-1.jpg313600Sidley Multisitehttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngSidley Multisite2025-10-09 14:05:292025-10-09 14:05:29Council on Environmental Quality Issues Long Awaited Guidance for Environmental Review Across Agencies
On September 29, 2025, the Trump Administration unveiled a sweeping set of policy initiatives aimed at revitalizing the U.S. coal sector that spans multiple federal agencies and includes measures such as increased funding and financial incentives, relief from environmental regulatory requirements, and increased access to public lands. In the unveiling, the Administration emphasized the importance of American “energy dominance” and the increased demand for electricity to power artificial intelligence (AI) in order to ensure that the United States wins “the AI arms race” — two themes commonly highlighted by the Administration and its top officials.
https://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Sidley Multisitehttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngSidley Multisite2025-10-07 15:43:332025-10-07 15:43:33EPA, Departments of Interior and Energy Announce New Coal-Friendly Policy Initiatives
The U.S. power grid is undergoing a period of rapid change, with federal agencies such as the Department of Energy (DOE) and the Federal Energy Regulatory Commission (FERC) initiating programs and regulatory actions to address the integration of new generation and transmission resources. According to a recent DOE report, the U.S. grid is facing the retirement of 104 GW of firm capacity (generation that can operate continuously) by 2030, and the planned addition of 209 GW of new generation in the same period. The White House is concerned that the retirement of “baseload” power plants will impede President Trump’s economic goals; as such, press reports say that the administration is expected to issue new emergency orders preventing fossil fuel plants from retiring.
https://energyinfrastructurepulse.sidley.com/wp-content/uploads/sites/7/2025/11/AdobeStock_9699481.jpg451600Sidley Multisitehttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngSidley Multisite2025-10-06 18:51:242025-10-06 18:51:24Interconnection Reform Critical to the Efficiency of Energy Markets
On September 16, 2025, the U.S. Environmental Protection Agency (EPA) published a proposed rule that would fundamentally reshape the federal Greenhouse Gas Reporting Program (GHGRP). 90 Fed. Reg. 44591 (Sept. 16, 2025). If finalized, this action would mark a further shift in federal greenhouse gas (GHG) policy and advance the administration’s broader deregulatory agenda.
https://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Sidley Multisitehttps://sidley-goodlifesci-wordpress.onistaged.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngSidley Multisite2025-09-22 16:37:092025-09-22 16:37:09EPA Proposes Overhaul of Greenhouse Gas Reporting Program
FERC’s First Meeting Under New Leadership: Key Takeaways and Signals for 2026
On November 20, 2025, the U.S. Federal Energy Regulatory Commission (FERC or the Commission) held its first monthly open meeting since the confirmation and swearing-in of Chairman Laura Swett and Commissioner David LaCerte.[1] It marks the first time FERC has had a full five-member commission since the departures of Commissioner Mark Christie and Chairman Willie Phillips earlier this year. FERC’s first meeting under new leadership coincided with an agenda that underscored urgency and a new strategic direction. The summary below outlines the Commission’s discussion and key actions.
(more…)
Terence T. Healey
Boston
thealey@sidley.com
Casey Khan
Houston
ckhan@sidley.com
Grace Dickson Gerbas
Dallas
gdicksongerbas@sidley.com
Charles A. Beauregard
Washington, D.C.
charles.beauregard@sidley.com
Bringing Data Centers to the Grid: FERC’s Emerging Large Load Framework
On October 23, 2025, Secretary of Energy Chris Wright directed the Federal Energy Regulatory Commission (FERC) to consider an Advance Notice of Proposed Rulemaking (ANOPR) to initiate rulemaking procedures to “ensure the timely and orderly interconnection of large loads to the transmission systems.” Under the ANOPR, “large loads” are defined as those with a capacity of 20 MW or more, aligning with the definition of “large generation sources” in FERC’s Order No. 2003.
(more…)
Terence T. Healey
Boston
thealey@sidley.com
Grace Dickson Gerbas
Dallas
gdicksongerbas@sidley.com
William W. Hendrickson
Houston
william.hendrickson@sidley.com
The Trump Administration’s Pushback Against a Global Shipping Carbon Levy
The International Maritime Organization (IMO), the United Nations agency tasked with regulating global shipping, has proposed an international carbon pricing scheme on shipping. The maritime shipping sector has increasingly faced global scrutiny as the contributor of 3% of global greenhouse gas emissions, and IMO’s proposed mechanism would serve as the first global emissions pricing mechanism affecting the shipping sector.
(more…)
Abigail Kuchnir
Chicago
abigail.kuchnir@sidley.com
Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Governors of PJM States Intensify Pressure on PJM for Reform
A bipartisan group of governors of PJM Interconnection (PJM) member states has intensified calls for reforming PJM after what they have described as a “crisis of confidence,” citing high electricity prices, interconnection delays, and lack of transparency and state participation in the RTO’s decision-making processes.
Terence T. Healey
Boston
thealey@sidley.com
Priya Kareddy
Washington, D.C.
priya.kareddy@sidley.com
Tanner L. Groce
Houston
tgroce@sidley.com
Council on Environmental Quality Issues Long Awaited Guidance for Environmental Review Across Agencies
On September 29, 2025, the Council on Environmental Quality (CEQ) issued long-awaited guidance to formalize agencies’ individual efforts to implement the National Environmental Policy Act (NEPA). After rescinding the CEQ regulations that shaped NEPA for 40+ years and bearing witness to various agencies’ independent efforts to issue their own NEPA rules, CEQ issued new guidance to more systematically guide the agencies’ efforts. As CEQ notes, “NEPA implementation reform now has been called for, authorized, and directed by all three branches of government at the highest possible level: Congress, the President, and the Supreme Court.” The guidance reflects direction from each.
(more…)
Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Peter Whitfield
Washington, D.C.
pwhitfield@sidley.com
Brooklyn Hildebrandt
Los Angeles
bhildebrandt@sidley.com
EPA, Departments of Interior and Energy Announce New Coal-Friendly Policy Initiatives
On September 29, 2025, the Trump Administration unveiled a sweeping set of policy initiatives aimed at revitalizing the U.S. coal sector that spans multiple federal agencies and includes measures such as increased funding and financial incentives, relief from environmental regulatory requirements, and increased access to public lands. In the unveiling, the Administration emphasized the importance of American “energy dominance” and the increased demand for electricity to power artificial intelligence (AI) in order to ensure that the United States wins “the AI arms race” — two themes commonly highlighted by the Administration and its top officials.
(more…)
Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Rose Quam-Wickham
Interconnection Reform Critical to the Efficiency of Energy Markets
The U.S. power grid is undergoing a period of rapid change, with federal agencies such as the Department of Energy (DOE) and the Federal Energy Regulatory Commission (FERC) initiating programs and regulatory actions to address the integration of new generation and transmission resources. According to a recent DOE report, the U.S. grid is facing the retirement of 104 GW of firm capacity (generation that can operate continuously) by 2030, and the planned addition of 209 GW of new generation in the same period. The White House is concerned that the retirement of “baseload” power plants will impede President Trump’s economic goals; as such, press reports say that the administration is expected to issue new emergency orders preventing fossil fuel plants from retiring.
Kenneth W. Irvin
Washington, D.C.
kirvin@sidley.com
Tiph Kugener
Houston
tiphaine.kuegner@sidley.com
Evan Grosch
EPA Proposes Overhaul of Greenhouse Gas Reporting Program
On September 16, 2025, the U.S. Environmental Protection Agency (EPA) published a proposed rule that would fundamentally reshape the federal Greenhouse Gas Reporting Program (GHGRP). 90 Fed. Reg. 44591 (Sept. 16, 2025). If finalized, this action would mark a further shift in federal greenhouse gas (GHG) policy and advance the administration’s broader deregulatory agenda.
(more…)
Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Brittany A. Bolen
Washington, D.C.
bbolen@sidley.com
Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Resources
Meet the Team
Cliff W. Vrielink
cvrielink@sidley.com
Kenneth W. Irvin
kirvin@sidley.com
Tara Higgins
thiggins@sidley.com
Herschel T. Hamner III
hmamner@sidley.com
James MacArthur
james.macarthur@sidley.com
Raymond A. Atkins Ph.D.
ratkins@sidley.com
Kevin P. Lewis
klewis@sidley.com